Plaintiffs' Answers to Interrogatories Concerning Expert Witnesses (Redacted)

    IN THE UNITED STATES DISTRICT COURT FOR THE 
MIDDLE DISTRICT OF ALABAMA 

NORTHERN DIVISION 

JOHN DILLARD, ET AL., * 

Plaintiffs, % 

vs. * CA NO. 85-T-1332-N 

CRENSHAW COUNTY, ALABAMA, ET AL. * 

Defendants. * 

PLAINTIFFS’ ANSWERS TO INTERROGATORIES 

CONCERNING EXPERT WITNESSES 
  

The plaintiffs through their undersigned counsel 

provide the following answers to the interrogatories propounded 

by Pickens County defendants and Etowah County defendants 

concerning expert witnesses which plaintiffs intend to use at 

trial: 

l ¥ 2a. Plaintiffs have already called Dr. Peyton 

McCrary of the history department at the University of South 

Alabama for the hearing on preliminary injunction. Dr. McCrary'’'s 

testimony and opinions are already a part of the record. 

Plaintiffs do not intend, at this time, to recall Dr. McCrary for 

—n 
£ of 4 ort 

 



  

any further testimony. 

l ¥ 2b. Plaintiffs intend to call Dr. Gordon Henderson. 

Dr. Henderson is a political scientist and will testify 

concerning his analysis of voting returns and the extent of 

raciallly polarized voting patterns and dilution of black voting 

strength. Dr. Henderson is also expected to testify about 

comparative voting turnout figures for black and white voters. 

Dr. Henderson may also testify more generally about the effects, 

socioeconomic status and past discrimination have on voting 

behavior. A copy of Dr. Henderson's curriculum vitae is 

attached. 

3. Plaintiffs will make available for inspection and 

copying their proposed districting plan for Pickens and Etowah 

County on Wednesday, July 16, 1986, in Montgomery, Alabama. 

th 
Respectfully submitted this /6& day of July, 1986. 

BLACKSHER, MENEFEE & STEIN, P.A. 
405 Van Antwerp Building 
P. O. Box 1081 
Mobile, AL 36633 

ie MT ID 
JAMES fu? Br 
LARRY !T. MENEFEE 
WANDA J. COCHRAN 

  

TERRY G. DAVIS 

 



  

y ® 

SEAY & DAVIS 
732 Carter Hill Road 

P.O. Box 6215 
Montgomery, AL 36106 
(205) 834-2000 

DEBORAH FINS 

JULIUS L. CHAMBERS 
NAACP Legal Defense Fund 
99 Hudson Street, 16th Floor 
New York, New York 10013 
(212) 219-1900 

EDWARD STILL 
REEVES & STILL 
714 South 29th Street 
Birmingham, AL 42233-2810 
(208) 322-6631 

REO KIRKLAND, JR. 

307 Evergreen Avenue 
P. O. Box 648 

Brewton, AL 36427 

(205) 867-5711 

Attorneys for Plaintiffs 

CERTIFICATE OF SERVICE 
  

il. I do hereby certify that on this // day of July, 1986, 

a copy of the foregoing PLAINTIFFS’ ANSWERS TO INTERROGATORIES 

CONCERNING EXPERT WITNESSES was served upon the following counsel 

of record: 

H. R. Burnham, Esq. Warren Rowe, Esq. 
Burnham, Klinefelter, Halsey, Rowe & Sawyer 

Jones & Carter P. O. Box 150 
P. O. Box 1818 Enterprise, AL 36331 
Anniston, AL 36202 (COFFEE COUNTY) 
(CALHOUN COUNTY) 

Jack Floyd, Esq. D. L. Martin, Esq. 

 



  

y % 

Floyd, Kenner & Cusimano 
816 Chestnut Street 
Gadesden, AL 35999 
(ETOWAH COUNTY) 

David R. Boyd, Esq. 
Balch & Bingham 
P. O. Box 78 
Montgomery, AL 36101 
(LAWRENCE COUNTY, SMITH & LIGON) 

¥. O. RIRR, dr., Esg. 
Curry & Kirk 
P. O. Box A-B 

Carrollton, AL 35447 

(PICKENS COUNTY) 

215 South Main Street 

Moulton, AL 35650 

(LAWRENCE COUNTY, SMITH & LIGON) 

James G. Speake, Esq. 
Speake, Speake & Reich 
P. O. Box 5 
Moulton, AL 35650 
(PROCTOR OF LAWRENCE COUNTY) 

Barry D. Vaughn, Esq. 
Proctor & Vaughn 
121 North Norton Avenue 
Sylacauga, AL 35150 
(TALLADEGA COUNTY) 

by depositing same in the United States mail, postage prepaid. 

for 10 
  Ty 

 



  

Curriculum Vitae 

January, 1986 

HENDERSON, Gordon Grant 

Age 

Home 

S54 Married 3 children 

address: 

{3 37) 

Positions held: 

1. 

tJ
 

Fresident, Gordon G6. Henderson, Inc. 

220 South 19th Street 

Richmond Indiana 47374 

Director of the Computing Center and 
Frofessor of Folitical Science 

Earlham College 

Richmond IN 47374 

Director of the Computing Center and 

Frofessor of Folitical Science 

Tougaloo College 

Tougaloo MB 39174 

Frofessor of Government 

Texas Tech University 

Lubbock TX 79409 

Fartner in DATA SURVEYS a survey research firm 

Suite 410 Arizona Title Building 
Fhoenix AZ as00T 

Special Assistant to the Governor 

Samuel FP. Goddard, Jr., of Arizona 

State Capitol 

Fhoenix AZ GHE5007 

Associate Frofessor of Folitical Science and 

Chairperson 

Department of Folitical Science 

Millsaps College 

Jackson MS F210 

Ingtructor in Political Science 

Department of Folitical Science 

Middlebury College 

Middlebury VT 

DHH-678% 

1984~date 

1980-1983 

1972-1980 

1968-1972 

1967-1968 

1965-19646 

1962-1966 

1957-19467 

 



i 34 

iy ny 

  

7. Lecturer in Government 

City College of New York 

New York New York 1954~19057 
10. Lecturer in Government 

Rutgers, The State University 
New Brunswick New Jersey 1994-1957 

Academic Freparation: 

A.B. Columbia College, 1933 
M.A. Columbia University, 1954 

Ph.D. Columbia University, 1962 

Academic interests by fields: 

American government and politics (policy analysis) 

Computer programming 

Folitical parties and voting behavior 

Research design and methods, including computer techniques 

Publications: 

Books: 

An Introduction to Political Farties (New York: 
Harper & Row, 1976) 
  

American Democracy: Feople, Politics, and Folicies 

(Cambridge: Winthrop, 1979) 
  

An Instructor®s Manual for American Democracy 
Feople, Politics, and Policies (Cambridge: Winthrop, 1979) 
1979) 

  

  

Student Guide, American Democracy: reople, Foliticsg, 
and Policies (Cambridge: Winthrop, 1980) 
  

  

Articles: 

"Teaching Elementary Statistics with a Computer—-Generated 
Individualized Student Dataset," DEA NEWS (Winter 1977).   

"Folicy by Default: The Origin and Fate of the *Frescott 
Letter’, 69 Political Science Quarterly (March 1944), 76~9%   

"The New Republicans of Mississippi," 20 New South 
(June 19245). 

  

"Notes on Mississippi," 20 New South (October 19465).   

"In a Time of Passage," 21 New South (Spring 1946) 
  

"If you Don’t Enow Where You Are Going, Any Road Will 
Take You There," Millsaps Bulletin (Spring 1964) 

  

 



  

Book Reviews: 

In Journal of Politics, Choice: Books for College 
Libraries, and the Mississippi Law Journal . 
  

  

  

Frofessional Memberships: 

American Folitical Science Association 
Midwest Political Science Association 
New England Political Science Association 
Folicy studies Organization 
Folitical Science Academy 
Southern Political Science Association 
Southwestern Political Science Association 
Western Political Science Association 

Farticipation in Professional Organizations: 

A. 1. Member of the Council, Mississippi Folitical Science 
Association, 1979-1981 

2. SBecretary-Treasurer of the Southwestern Folitical Science 
Association, 1970-1973 

. Secretary of the Southern Political Science Association, 
19465-19466 

4. Fresident, Middlebury College Chapter of the American 
Association of University Frofessors, 1961-1942 

B. Currently serve as referee for articles/notes for Journal 
of Folitics, Polity, American Journal of Political Science, 
and the Western Folitical Quarterly. 
  

  

Ce. Member of NSF proposal review panels, 1977, 1978, 1980 

BD. Member of the faculty of the National Science Foundation-— 
sponsored Conference on Educational Computing in Minority 

Institutions, New Orleans, Louisiana, March 1977. 

EE. Delivered papers and/or chaired panels at 

(a) annual meeting of the Southern Folitical Science 
Association, 1981, 1976, 1970, 1946, 1964, 1963 

(b) annual meeting of the American Political Science 
Association, 1963 

(c) annual meeting of the Southwestern Folitical Science 
Association, 1970 

(d) annual meeting of the Rocky Mountain Political Science 
Association, 1969 

   



  

Grants and awards: 

Coauthor of grant ($608,000) funded by Lilly Endowment for 

support of computing at Earlham College 

Coauthor of grant ($130,000) funded by Lilly Endowment for 

support of social sciences at Tougaloo College, 1979 

Coauthor of grant ($272,000) funded by National Science Foundation 

in support of science education, 1978 

Froject director of grant ($313,000) funded by National Science 

Foundation in support of science education at Tougaloo College, 

1973-1976 

Research grant from Texas Tech University to conduct a survey of 
political attitudes in Lubbock, Texas, 1970 

Recipient of post-doctoral fellowship from the National Center for 
Education in Folitics, under which I served as Special Assistant to 

the Governor, Samuel PF. Goddard, Jr., of Arizona, 1945-19664 

Director of the Field Foundation grant to Millsaps College to 
establish the Oral History of Contemporary Mississippi Life and 
Viewpoints, 1963 

Farticipant in" Conference on Mathematical Applications 

in Folitical Science," sponsored by the National Science 

Foundation, held at Southern Methodist University, Dallas, Texas, 
summer, 1964 

Recipient of grants from the Faculty Research Fund of Millsaps 

College to aid in the preparation of data which appeared in 

New South. 19461 AND 19463 
  

Recipient of grant from the Merrill Foundation to conduct a 

survey of voter attitudes in Hinds County, Mississippi, in the 
summer of 19463 

Recipient of DuFont Research Grant from Middlebury College which 
resulted in publication of article in the Political Science 
Cuarterly, 1941 

  

  

 



Finan 

{ ‘ 

Cases in which I have testified as an expert witness 

NOTE: Case names preceded by an asterisk (XxX) are more 
fully described on the next page 

Reapportionment, redistricting and election cases 

X Bandemer v. Davis (The Indiana reapportionment case), Federal 

District Court (Southern Indiana) 

Bassett v. Roberts, Federal District Court (Southern MS) 

Boykins v. City of Hattiesburg, Federal District Court (Southern MS) 

Challenge to at-large elections; decision for plaintiffs, 1984) 

Brooks v. Winter, Federal District Court (Northern MS) 

Buckanaga v. Sisseton Independent School District, Federal 

District Court, South Dakota 

Connor v. Johnson through Connor v. Finch, Federal District Court 

(Southern MS) 

Farnum v. Burns, Federal District Court (Rhode Island) 

Holmes v. Burns, Superior Court Rhode Island 

Jordan v. City of Greenwood, Federal District Court 

(Northern MS); decision for plaintiffs, 1984. 

Kirksey v. City of Jackson, Federal District Court (Southern MS) 

Kirksey v. Danks, Federal District Court (Southern MS) 

Kirksey v. Hinds County Board of Supervisors, Federal District 

Couwrt (Southern MB) 

Latino Political Action Committee v. City of Boston, Federal 

District Court (Eastern District MA) 

Licht v. Quattrochi, Superior Court Rhode Island 

Major v. Treen, Federal District Court, Louisiana 

Marshall v. East Carroll Farish, Federal District Court (Western LA) 

Mississippi v. United States, Federal District Court (DC) 

Farnell v. Rapides Farish, Federal District Court (LA) 

Sanchez v. King, Federal District Court (New Mexico)  



ad 

TIAV. Terrebone Parish, Federal District Court (LA) 

  

TIA v. Houma, Federal District Court (LA) 

¥ Windy Boy v. Big Horn County, Federal District Court, 
Montana 

Title VII cases: 

Boykin v. Georgia-Pacific, Federal District Court (Southern MS) 

EEOC v. Beorgia~Facific, Federal District Court (Northern MS) 

EEOC vo. Union Flanters Bank, Federal District Court (TN) 

Gottlieb v. Tulane University, Federal District (LA) 

Helen Hall v. Small Business Administration, Federal District 
Court (Southern MS) 

Hubbs v. United Parcel, Federal District Court (Southern MS) 

¥ Mayfield v. Auburn University, Federal District Court (Southern AL.) 

¥ Fhillips v. Attorney-General of Mississippi, Federal District 
Court (Southern Ms) 

Other: 

I have also testified in several cases tried in the state courts 
of Mississippi with respect to Jury selection procedures, as an expert 
in statistics in Rattle v. Jefferson Davis Memorial Hospital (U. 8S. 
District Court, Southern District of Mississippi), and as an expert 
in an asbestos suit against the Mansville Company and others 
heard in the U. 8. District Court for the Southern District of 
Mississippi 

I have also been retained as a consultant and as a potential 
expert witness by attorneys in both districting and Title VII 
cases that have been settled before trial, and have done analyses 
of data in a number of cases that have not vet come to trial. 

Court appearances by Gordon 6G. Henderson in 1982-1985 

Bandemer v. Davis (Three-judge federal district court, southerndistrict 
of Indiana). Challenge to reapportionment of Indiana legislature 
brought by Democrats. Employed on behalf of plaintiffs to 
critique states plan. Decision for plaintiffs. 

Brooks v. Winter (Three-judge federal district court, northern 
district of Mississippi, 1983). Challenge to redistricting of 
of 2nd congressional district of Mississippi on ground of vote 
dilution. Presented regression analysis of racial bloc voting, 
and critique of challenged plan. Judgment for Black plaintiffs. 
Assisted in drawing of plan adopted by the Court. 

 



    
° ® u 

Buckanaga v. Sisseton Independent School District (Federal 
District Court, South Dakota, 1985). Challenge by Indian plaintiffs 
to use of at-large elections. Employed by plaintiffs 
attorneys to do study of socioeconomic status and racial bloc 
voting. Case on appeal from adverse decision by District Court 

  

Farnum v. Burns (Three—judge federal district court, district of Rhode 
Island, 1983). ‘Challenge to reapportionment of Rhode Island Senate 
brought by Republican Party members. Employed by plaintiffs’ 
attorneys. Drew plan for greater Providence area, the area where 
gerrymandering was alleged to have been done. Flantiffs successful. 
Henderson plan ordered into effect by court. 

Holmes v. Burns (Rhode Island Superior Court, 1982). Challenge to the 
reapportionment of the Rhode Island House of Representatives brought 
by Republican Party members. Employed by plaintiffs’ attorney. 
Drew demonstration plan. Critigued state’s plan. Plaintiffs 
unsuccessful. 

latino Folitical Action Committee v. City of Boston (Federal 
district Court, MA). 2 suits by plaintiffs challenging the 
redistricting of the Boston City Council and School Committee. 
Flaintiffs successful in first suit; no decision in second. 

Licht v. Guattrocchi (Rhode Island Superior Court, 1982). Challenge 
to the reapportionment of the Rhode Island Senate brought by one 
Democrat and one Republican senator. Employed by plaintiffs’ 
attorney. Drew demonstration plan. Critigued state's plan. 
Flaintiffs successful. 

Major v. Treen (Three-—judge federal district court, Louisiana, 1983). 
Challenge to reapportionment of congressional districts brought 
by Black plaintiffs. Employed by plaintiffs’ attorney. Drew plan. 
Critiqued states plan. Did extensive racial bloc voting and other 
analyses. Flaintiffs successful. 

Mayfield v. Auburn University (Federal district court, Southern 
Alabama, 1983). Employed on behalf of plaintiff who claimed 
sex discrimination by the University. Did extensive (over 
00 tables of data) analysis of data on hiring, promotion, 
tenure, salaries, etc. Plaintiff unsuccessful. On appeal. 

Fhillips v. Attorney-General of Mississippi (Federal District 
Court, Southern Mississippi, 1983). Employed on behalf of 
plaintiffs who claimed race discrimination in the hiring 
practices of the Office of Attorney-General of Mississippi. 
Decision for plaintiffs, 1984. 

Sanchez v. King (Three-judge federal district court, New Mexico, 1982). 
Challenge to data used in and reapportionment of both houses of the 
New Mexico Legislature brought by Hispanic and Native American 
plaintiffs. Employed by plaintiffs’ attorney. Drew demonstration plan 
Critiqued states plan. Did demographic and other analyses. 
Flaintiffs successful in both cases. 

Windy Boy v. Big Horn County (Federal District Court, Montana, 1985). 
Suit by Indian plaintiffs challenging use of at-large elections. 
Employed by plaintiffs attorneys. Did analysis of socioeconomic 
status and relationship between status and political participation. 

Drew redistricting plan for five-member council of the Town of 
West Warwick, Rhode Island, November, 1983.  



BLACKSHER, MENEFEE & STEIN, P.A. 

ATTORNEYS AT LAW 

P.O. Box 1051 

MoBILE, AL 36633-1051 

Julius I. Chambers, Esquire 
Deborah Fins, Esquive™ 
Legal Defense Fund 
99 Hudson Street 
16th Floor 
New York, New York 10013